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Personal data processing policy

This policy on the processing of personal data is prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures taken by LLC "GMT" (LLC "Global Medical Technologies," hereinafter referred to as the "Operator") to ensure the security of personal data.

1. General Provisions
1.1. The Operator considers the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal, and family secrets, as its most important goal and condition for conducting its activities.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://rzn.expert/en.

2. Key Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://rzn.expert/en.
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data – actions resulting in the inability to determine the ownership of personal data by a specific User or other subject of personal data without using additional information.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://rzn.expert/en.
2.9. Personal data permitted for dissemination – personal data to which access by an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter referred to as "personal data permitted for dissemination").
2.10. User – any visitor to the website https://rzn.expert/en.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or familiarizing an unlimited group of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.

3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:

Receive reliable information and/or documents containing personal data from the subject of personal data.

Continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law.

Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

Provide the subject of personal data, upon request, with information regarding the processing of their personal data.

Organize the processing of personal data in accordance with the current legislation of the Russian Federation.

Respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law.

Provide the authorized body for the protection of the rights of subjects of personal data with the necessary information within 30 days from the date of receipt of such a request.

Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data.

Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data.

Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law.

Perform other duties stipulated by the Personal Data Law.

4. Key Rights and Obligations of Personal Data Subjects
4.1. Subjects of personal data have the right to:

Receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form and should not contain personal data related to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law.

Demand that the Operator clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights.

Set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market.

Withdraw consent to the processing of personal data.

Appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator in the processing of their personal data.

Exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:

Provide the Operator with accurate information about themselves.

Inform the Operator about the clarification (updating, modification) of their personal data.

4.3. Persons who provide the Operator with false information about themselves or information about another subject of personal data without the latter's consent are liable in accordance with the legislation of the Russian Federation.

5. Personal Data Processed by the Operator
5.1. The Operator may process the following personal data of the User:

Last name, first name, and patronymic.

Email address.

Phone numbers.

Name of the medical device.

5.2. The website also collects and processes anonymized data about visitors (including "cookies") using internet statistics services (Yandex Metrica, Google Analytics, and others).

5.3. The above data is collectively referred to as "Personal Data" in this Policy.

5.4. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life.

5.5. Processing of personal data permitted for dissemination from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is allowed if the prohibitions and conditions stipulated by Article 10.1 of the Personal Data Law are observed.

5.6. The User's consent to the processing of personal data permitted for dissemination is issued separately from other consents to the processing of their personal data. The requirements for the content of such consent are established by the authorized body for the protection of the rights of subjects of personal data.

5.7. The User provides consent to the processing of personal data permitted for dissemination directly to the Operator.

5.8. The Operator is obliged to publish information on the conditions of processing, prohibitions, and conditions for the processing of personal data permitted for dissemination by an unlimited number of persons within three working days from the receipt of the User's consent.

5.9. The transfer (distribution, provision, access) of personal data permitted for dissemination by the subject of personal data must be terminated at any time at the request of the subject of personal data. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the subject of personal data, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Operator to whom it is addressed.

5.10. Consent to the processing of personal data permitted for dissemination ceases to be valid from the moment the Operator receives the request specified in clause 5.9 of this Policy.

6. Principles of Personal Data Processing
6.1. The processing of personal data is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
6.3. The merging of databases containing personal data processed for incompatible purposes is not allowed.
6.4. Only personal data that meets the purposes of their processing is subject to processing.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not allowed.
6.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows the identification of the subject of personal data for no longer than required by the purposes of processing, unless the storage period is established by federal law, a contract, or an agreement to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or in the event of the loss of the need to achieve these purposes, unless otherwise provided by federal law.

7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data:

Informing the User by sending emails.

Conclusion, execution, and termination of civil law contracts.

7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending an email to the Operator at info@rzn.expert with the subject line "Opt-out of notifications about new products and services and special offers."

7.3. Anonymized User data collected through internet statistics services is used to collect information about User actions on the website, improve the quality of the website, and its content.

8. Legal Grounds for Processing Personal Data
8.1. The legal grounds for the Operator's processing of personal data are:

Federal Law "On Information, Information Technologies, and Information Protection" No. 149-FZ of July 27, 2006.

Federal laws and other regulatory legal acts in the field of personal data protection.

User consent to the processing of their personal data and to the processing of personal data permitted for dissemination.

8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://rzn.expert/en or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User agrees to this Policy.

8.3. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (enabling the storage of "cookies" and the use of JavaScript technology).

8.4. The subject of personal data independently decides to provide their personal data and gives consent freely, voluntarily, and in their own interest.

9. Conditions for Processing Personal Data
9.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or the law, to carry out the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body, or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the execution of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for the conclusion of a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
9.6. The processing of personal data to which an unlimited number of persons have access is carried out, provided by the subject of personal data or at their request (hereinafter referred to as "publicly available personal data").
9.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

10. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

10.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
10.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator at info@rzn.expert with the subject line "Updating personal data."
10.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by the contract or current legislation.
The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to info@rzn.expert with the subject line "Withdrawal of consent to the processing of personal data."

10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently familiarize themselves with the specified documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

10.6. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.

10.7. The Operator ensures the confidentiality of personal data when processing personal data.
10.8. The Operator stores personal data in a form that allows the identification of the subject of personal data for no longer than required by the purposes of processing, unless the storage period is established by federal law, a contract, or an agreement to which the subject of personal data is a party, beneficiary, or guarantor.

10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, or the withdrawal of consent by the subject of personal data, as well as the identification of unlawful processing of personal data.

11. List of Actions Performed by the Operator with Received Personal Data
11.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
11.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without it.

12. Cross-Border Transfer of Personal Data
12.1. Before starting the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the transfer of personal data is planned provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements can only be carried out if the subject of personal data has given written consent to the cross-border transfer of their personal data and/or the execution of a contract to which the subject of personal data is a party.

13. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the subject of personal data, unless otherwise provided by federal law.

14. Final Provisions
14.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at info@rzn.expert.
14.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://rzn.expert/en/politics.
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Moscow, Voekhonka Street, 15
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